Published on the UDRI website on 20/05/2013

U R BAN DESIGN RESEARCH INSTITUTE

43, Dr. Y. B. Gandhi Morg, Kaloghodo, Fort, Mumbai 400 023 Indio Telephone: 9 1 2265735773 Email : info@udri.orgWebsite: www.udri.org

Subodh Kumar

Municipal Commissioner

Municipal Corporation of Greater Mumbai

MCGM Headquarters

Mahapalika Marg

Mumbai 400 001

26" July 2011

Dear Sir,

Re: Revision of the Development Plan for Mumbai 2014-2034 - HOUSING

As you may be aware the UDRI has initiated a public participation process in order to create a 'People

Brief' to inform the formulations of the revisions to the Development Plan for Mumbai 2014-2034. This

process has involved a series of meeting of 'stakeholder' groups consisting of NGOs working on the

ground, Researchers, Former government officers and Experts coming together to look at the various

issues in Mumbai such as Housing, Transportation, Water, Energy, livelihood, Governance,

Environment, Health, Education, Urban Form and Finance.

The intention is to sha re with the MCGM the suggestions and recommendations made by the

stakeholders and we hope that you w ill allow us to share these also with the consultant commissioned

to prepare the development plan.

With this letter the housing group wishes to put before you the following suggestions:

1.0 Background

1.1 Requirement for inclusive housing in Mumbai

The transform report (2008 - 'Comprehensive Transport Study of the MMR' conducted by LEA

Associates and commissioned by the MMRDA) estimates population of Greater Mumbai living in slums

and wadis in 2005 as 6.5 million people (51% of the population). That is a shortfall of about 15 Lakh

dwelling units as of 2005. The 2011 census may show that this figure is nearing 70%.

1.2 Ava ilability of Land for inclusive Housing

The transform report also estimates that "41% of the total land area of Greater Mumbai (438 sq km) is

considered as No Development zone for a number of reasons largely related to environmental

constraints or for parks and open space preservation. There is less than 10 sq km of designated land yet

to be developed in Greater Mumbai". There is an urgent need to increase land availability to

accommodate the future growth ofthe city. This can be done by building more bridges to the

Published on the UDRI website on 20/05/2013

U R BAN DESIGN RESEARCH INSTITUTE continuation sheet

mainland, and by re-visiting the decision on No-Development zones, particu larly where such zones do

not serve any public interest.

1.3 Over pricing created by Speculative Housing

It is imperative that a large amount of affordable housing stock be created to flood the housing market

and break the unaffordable prices created by speculative housing.

2.0 Premise

2.1 Housing as a fundamental right of all humans

The State government needs to recognise that housing is a fundamental right without which no human

being can achieve his full potential. The most urgent priority that the City of Mumbai needs to grapple

with is the provision of inclusive housing for all who wish to live here.

2.2 No Free Housing

Though housing is a fundamental right, this should be provided through enabling environment that

promotes self help and low-cost housing by providing tenure and implementing of policies that will

ensure the creation of inclusive housing both for ownership and rent by private players.

2.3 Housing and Land for housing not a profit making venture for government agencies

Real Estate and low-income housing cannot be seen as a financing mechanism for the city. Housing is to

be provided at cost and to cover the administrative costs of doing so (MHADA model of 10 to 15 %

overhead on cost of construction as sale price)

2.4 Implement Cap less FSI

FSI has been distorted from a planning tool into a commodity. It has been manipulated so as not to

lower real estate prices. There is a need to de-commodify/de-construct FSI by completely removing it

through a mechanism of form based controls and implementing instead a density cap.

2.5 Political will needed

Without a strong political will from the state government to make housing as the most urgent item on

its agenda for Mumbai, and without stringent enforcement from the top down through to all levels of

the bureaucracy, the success of any housing initiative will remain a pipe dream.

3.0 Strategy for inclusive housing

3.1 Remove FSI

Remove the cap on FSI completely. Let building control define the building based on factors such as

open space, setbacks, plot size and dimensions, access way width etc. Many cities already use such a

matrix to define built up are. Also specify a density cap. This wou ld mean that smaller units would be

Published on the UDRI website on 20/05/2013

U R BAN DESIGN RESEARCH INSTITUTE continuation sheef

built at lower FSI while larger units of the luxury market would be built at higher FSI. This is to ensure

there is an adequate distribution of public amenities within the density of population.

3.2 All existing tenable slum land to be a DP reservat ion for affordable housing only

All slums land on tenable land should be reserved in the DP as reservations for affordable housing for

existing dwellers. Any remaining dwelling units that are created should also be only for affordable

housing. No HIG or commercial development should be allowed on this land. Once land is delineated as

slum area this wil l need to be notified and mapped and demarcated on the ground.

3.3 Slum redevelopment-tenable land through creation of Cooperative Housing Society

For slums located on tenable land, Housing clusters to form Cooperative Housing Society (CHS) and

land tenure to be provided to the CHS on long term lease. The CHS will initiate in-situ redevelopment

on an incremental basis or through loan from financing institution. If within the specified density cap,

any dwelling units can be built over and above the re-housing requirement, 50% of these should be

given to MHADA for sale through its lottery system.

3.4 Slum redeve lopment - non tenable land and project displaced

For slu m dwellings located on Non-tenable landJsuch as railway/airport reservations, NDZ, CRZ land) or

those persons displaced by projects, housing is to be provided by MHADA on rental or ownership basis

using the lottery system.

3.5 New Construction to provide 50% all floor space for inclusive housing

All new construction, whether for residential or commercial or industrial development to have 50% of

the total built floor space set aside in-situ for housing as EWG and LlG housing units. These units will be

built as per DCRs on par w ith other housing projects (not SRA type). These units will be handed over to

MHADA by the developer. MHADA will pay the cost of construction for the same, but not the cost of

land. MHADA will se ll these through its lottery system or assign to a non-profit rental agency for

management.

3.6 Redevelopment of existing societies/buildings

For redevelopment projects - half of all new units to be developed as sale component and to be EWG

and LlG housing. These to be handed over to MHADA who will pay the cost of construction of the units

that are handed over. MHADA is to sell these through its lottery system or assign to a non-profit rental

agency for management.

3.7 Cessed and rent control buildings

For Cessed/Rent control bui ldings no new tenancy to be created and any transfer of tenancy to

automatically invalidate rent control.

I

Published on the UDRI website on 20/05/2013

U R BAN DESIGN RESEARCH INSTITUTE

3.8 Heritage buildings/precincts with or without rent control

continuation sheet

For Heritage buildings or heritage precincts, the Owner is to maintain the building as per the heritage

committee guidelines. An incentive based on TOR for transfer within the same area may be considered

for the loss of development rights.

3.9 Non Heritage buildings within Heritage precincts with or without rent control

For Non-Heritage buildings or buildings in heritage preCincts with cap on FSI and height control ­

building to be redeve loped as per the restrictions of height and maSSing for the heritage precinct

prescribed by the heritage committee.

3.10 Administration of affordable rental housing

Non-profit agencies will administer the rental housing. Housing is assigned based on the space

requirement of the family and the amount of subsidy to be given will be determined by the family's

income. This assessment is done family by family. The rental agency maintains and manages the rental

housing units and collects rent from tenants as well as a subsidy from the government. A mechanism

can also be created for a buyout of the rental space by the tenant over a period of years.

These are our initial suggestion s for your consideration. We will be looking at how we can build on

these strategies in the future deliberations of the group and will follow up on these suggestions in

greater detail. In the meantime we would be happy to have feedback or comments from the

consultants in order to engage with them on this process. We will also be happy to further elaborate

these suggest ions to you in person if you should allow us this opportunity.

Thanking You,

Yours Sincerely

Ajit Ranade

___ C-,"~_ie_f_E~0tU~ . ~ • uf Kadri .:;:::.......--

~ect

Shirish Patel Civil Engineer and Planner

Amita Bhide Associate Professor·TISS

Former Mayor of Mumbai

Varsha Parchure Apnalaya

Neera Adarkar Architect

Simpreet Singh Ghar Banao Ando!an

Pankaj Joshi Urban Design Research Institute